Sunday, December 6, 2015

Demand that ETP and its Contractors be Held Accountable for Cuero Explosion

Image from Victoria Advocate: https://www.victoriaadvocate.com/news/2015/dec/06/pipeline-operator-wont-be-penalized-for-explosion/


According to an article in today's Victoria Advocate, The Texas Railroad Commission will not fine ETP for the June explosion of their faulty 42" pipeline in Cuero, TX.

"The explosion occurred about 8 p.m. June 14 and shot flames hundreds of feet into the air. The fire could be seen from 50 miles away. The heat from the flames melted electric lines, cutting off power to 130 homes. Sixteen people were evacuated from homes near the explosion, according to the report.
No one was injured in the incident, which caused $500,000 in damage."

Please write or call the following agencies to demand accountability for the operators of the pipeline and the contractor responsible for its installation:

Railroad Commission of Texas:

Pipeline Safety:
    • Main line 512/463-7058
    • Email: safety@rrc.texas.gov

Pipeline and Hazardous Materials Safety Administration:

Office of Pipeline Safety - Southwest Region Office
8701 South Gessner, Suite 1110
Houston, TX 77074
Telephone: 713-272-2859
Fax: 713-272-2831
Regional Director: Rod Seeley
CATS Manager: Bill Lowry
Direct: Phone: (713) 272-2845
E-mail: Bill.Lowry@dot.gov

Pipeline and Hazardous Materials Safety Administration
1200 New Jersey Avenue SE
East Building, Second Floor (PH)
Washington D.C. 20590-0001
Administrator: Cynthia L. Quarterman
Media Contact - Deputy Director, Office of Governmental, International and Public Affairs: Patricia Klinger
Associate Administrator for Pipeline Safety: Jeff Wiese
Phone: 202-366-4595

The operating company is Energy Transfer Company, RCT Operator number 32099.  The 42” REM pipeline is covered under State operating permit (T4) 08278.  The incident report and inspection package number is 111385, issued by the investigating agency, the Railroad Commission of Texas.

Sample letter:


John Q. Public
1234 Avenue A
AnyTown, TX 77027
jqpublic@gmail.com
555-555-1212

Office of Pipeline Safety - Southwest Region Office
8701 South Gessner, Suite 1110
Houston, TX 77074
CATS Manager: Bill Lowry

Good day Mr. Lowry;

I am writing in regard to a concern, raised by a recently concluded pipeline incident investigation, conducted by the Railroad Commission of Texas, related to the rupture, explosion, and fire associated with the 42” Rich Eagle Ford Mainline (REM) system operated by Energy Transfer Company. The incident occurred on June 14, 2015, near the town of Cuero, Texas. Railroad Commission of Texas (“RCT”), in its Pipeline Safety Evaluation, and Inspection Package, number 111385, published on November 2, 2015 concluded that material failure, as a result of bending stress, led to the rupture, explosion, and fire.

RCT's inspection package fails to state in a clear manner the root cause of the bending stress – improper installation by the contractor that constructed the pipeline. RCT failed to fine, or otherwise cite either the pipeline operating company, Energy Transfer Company, or the installation and construction contractor, Pumpco, Inc. In studying the RCT's inspection package, the root cause of the failure leading to the rupture, explosion, and fire of the 42” REM system was a bending radius in excess of the minimum. This in turn led to the failure of the material at the weld in this segment of pipe. This is clearly a failure on the part of the construction contractor – RCT's inspection package misleads the public, citing “material failure”, rather than stating the root cause, improper installation by the construction contractor.

Energy Transfer Partners, the parent of Energy Transfer Company, the pipeline operator, is also the parent of Mas-Tec, Inc., who in turn is the parent company of PumpCo, Inc., the construction contractor. Energy Transfer Partners, under variousoperating company entities, operates thousands of miles of pipeline systems, significant portions of which were installed by PumpCo or Mas-Tec associated contractors, sub-contractors, and related entities. The rupture, explosion, and fire associated with the 42” REM system, and the inadequate investigation, of the RCT in this event calls into question not only the public safety issues, but the integrity of the regulatory, safety oversight, and enforcement of pipeline systems under the jurisdiction of the RCT.

A copy of the RCT's inspection package, number 111385 is attached for reference. The operating company, Energy Transfer Company, Texas Operator ID 32099, and the 42” REM system, under RCT's T-4 permit 08278 are the identifiers of record associated with the system.

Your agency's attention to this matter would be appreciated. Without oversight, the RCT's lax procedures place the public in great peril.

Thanks and regards,
John Q. Public

MORE INFORMATION:



Here is an image, composited from the Railroad Commission of Texas GIS system, and Google Earth Pro - it overlays the site of the 42” REM pipeline rupture to show the relationship between the explosion site, and the nearby home, and the small, historic community of Lindenau, home to the Lindenau School, and Lindenau Hall. The community has a population of about 50 residents.

It is about five miles northwest of Cuero. The rupture and explosion on the 42”
REM pipeline melted the road, cut off power to the community, and exposed the area residents to the products of combustion from a “rich” wet gas stream, with a hydrogen sulfide (H2S) concentration at 19ppm (based on RCT T4 permit 08278 data, p. 68). H2S was used as a chemical weapon during World War I, and has the following toxicity effects at the indicated concentrations:

• 0.00047 ppm or 0.47 ppb is the odor threshold, the point at which 50% of a human panel can detect the presence of an odor without being able to identify it.
• 10 ppm is the OSHA permissible exposure limit (PEL) (8 hour time-weighted average).
• 10–20 ppm is the borderline concentration for eye irritation.
• 20 ppm is the acceptable ceiling concentration established by OSHA.
• 50 ppm is the acceptable maximum peak above the ceiling concentration for an 8-hour shift, with a maximum duration of 10 minutes.
• 50–100 ppm leads to eye damage.
• At 100–150 ppm the olfactory nerve is paralyzed after a few inhalations, and the sense of smell disappears, often together with awareness of danger.
• 320–530 ppm leads to pulmonary edema with the possibility of death.
• 530–1000 ppm causes strong stimulation of the central nervous system and rapid breathing, leading to loss of breathing.
• 800 ppm is the lethal concentration for 50% of humans for 5 minutes exposure (LC50).
• Concentrations over 1000 ppm cause immediate collapse with loss of breathing, even after inhalation of a single breath.

We don’t really know the H2S concentration in the gas stream, other than what is reported on the RCT form T4… This system, based on its location in a rural area, is designated as a Class I, which uses the minimum mechanical strength pipeline for the maximum operating pressure of 1300PSIG - identical to that planned for use in Alpine, and throughout the entire length of the proposed Trans-Pecos Pipeline. While the proposed Trans-Pecos Pipeline won’t carry “sour” gas with H2S in the stream, it will be subject to exactly the same problems as the 42” REM system near Cuero. The same contractor that installed the 42” REM system is also the installation contractor for the proposed Trans-Pecos Pipeline...

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